Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 18 of 42
1
Carthage is located mostly outside the north-central edge of the study area, and
2
Gary City is located in the central portion of the study area, east of Lake Murvaul.
3
4
Q28.
WHAT ARE BURNS & MCDONNELL'S FINDINGS REGARDING
5
PROXIMITY TO HABITABLE STRUCTURES IN THE VICINITY OF THE
6
PROPOSED ROUTES?
7
A.
Burns & McDonnell determined the number, distance, and direction of habitable
8
structures located within 500 ft. of the centerline of each route through
9
interpretation of aerial photography and verification during the reconnaissance
10
survey along public roads, where possible.
11
reasonable and in accordance with the policy of prudent avoidance, attempted to
12
avoid habitable structures in the routing of the preliminary, primary, and proposed
13
routes.
14
Burns & McDonnell, to the extent
The number of habitable structures located within 500 ft. of the proposed
15
routes' centerlines ranges between 13 and 27.
16
fewest habitable structures within 500 ft. of the centerline (13 structures).
17
other two Southern routes (RP50 and RP82) have between 21 and 24 structures
18
within 500 ft. The Central routes (RP10, RP28, RP41, and RP46) followed Route
19
RP53 with 15 to 20 structures within 500 ft., while the Northern routes (RP4,
20
RP5, RP8, RP16, and RP93) had the most structures within 500 ft. (between 21
21
and 27).
22
structures within 500 ft., because they parallel existing transmission lines for
23
more of their length than the other proposed routes, some of these structures are
Route RP53 (Southern) has the
The
While the Northern routes have the greatest number of habitable
700
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 19 of 42
1
already located close to an existing line, thereby limiting the overall impact of
2
these proposed routes on the habitable structures. Figure 8-1 (map pocket) shows
3
the location of each habitable structure, and Table 8-6 lists the types of habitable
4
structure, the direction and distance from the closest segment component of each
5
proposed route, and the unique identification number assigned to each habitable
6
structure depicted in Figure 8-1.
7
8
Q29.
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
9
AM RADIO TRANSMITTERS WITHIN 10,000 FEET OF THE CENTERLINE
10
AND OTHER TYPES OF ELECTRONIC INSTALLATIONS WITHIN 2,000
11
FEET OF THE CENTERLINES OF THE PROPOSED ALTERNATIVE
12
ROUTES?
13
A.
Communication towers were identified using GIS data obtained from the Federal
14
Communications Commission, aerial interpretation, and the field reconnaissance
15
survey. The PUCT requires the identification of the following communication
16
towers:
17
•
18
19
Commercial AM radio transmitters within 10,000 ft. of the route
centerline; and,
•
All FM radio transmitters, microwave relay stations, or other similar
20
electronic installations within 2,000 ft. of the centerline.
21
There are no commercial AM communication towers within 10,000 ft. of
22
any of the proposed routes. The Southern routes (RP50, RP53, and RP82) have
23
the fewest other communication towers within 2,000 ft. (0 to 2 towers). The
701
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 20 of 42
I
Central routes (RP 10, RP28, RP41, and RP46) have the next fewest, with between
2
2 and 6 towers within 2,000 ft. The Northern routes (RP4, RP5, RP8, RP 16, and
3
RP93) have the greatest amount of towers, between 6 and 11 towers within 2,000
4
ft. Table 8-9 in the EA lists the towers within 2,000 ft. of each route, with the
5
type, direction, and distance to the closest segment. These towers are also shown
6
on Figure 8-1 (map pocket).
7
No significant impacts to the operation of communication installations are
8
anticipated from any of the proposed routes.
9
10
Q30.
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
11
KNOWN PRIVATE AIRSTRIPS WITHIN 10,000 FEET, FEDERAL
12
AVIATION ADMINISTRATION ("FAA") REGISTERED AIRPORTS WITHIN
13
20,000
14
CENTERLINES OF THE PROPOSED ALTERNATIVE ROUTES?
15
A.
FEET,
AND HELIPORTS WITHIN 5,000 FEET OF THE
Burns & McDonnell identified airports along the proposed routes from the field
16
reconnaissance survey, aerial interpretation, public comments from the open
17
houses, aeronautical charts, and GIS data obtained from the FAA National Flight
18
Data Center.
19
airstrips, the name of the airstrip (if known), and the direction and distance of the
20
airstrip from the closest segment. Two of the Northern routes (RP16 and RP93)
21
are within 20,000 ft. of the Panola County-Sharpe Field (shown on Figure 3-2 in
22
the EA), which is a FAA-registered airport with a runway greater than 3,200 ft. in
23
length. No proposed routes are within 10,000 ft. of any FAA-registered airstrips
Table 8-8 in the EA shows the FAA registration status of the
702
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 21 of 42
I
or airports with runways less than 3,200 ft. in length.
2
(Hilltop Springs Airport) was identified within 10,000 ft. of the centerline of
3
Routes RP5, RP8, and RP16 (Northern); RPIO, RP28, RP41, and RP46 (Central);
4
and RP50, RP53, and RP82 (Southern). No heliports were identified within 5,000
5
ft. of any proposed route.
6
calculations, FAA notification will not be required for any airstrips as a result of
7
this Project.
8
private airstrip are approximately 4,400 ft. away and lower in elevation, the routes
9
are not anticipated to impact the airstrip, using a 20:1 approach slope.
One new private airstrip
Based on Bums & McDonnell's preliminary
Due to the fact that the proposed routes in the proximity of the
10
11
Q31.
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
12
AREAS IRRIGATED BY TRAVELING IRRIGATION SYSTEMS IN THE
13
VICINITY OF THE PROPOSED ALTERNATIVE ROUTES?
14
A.
15
No mobile irrigation systems were identified that would be crossed by any of the
proposed routes.
16
17
Q32.
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
18
COASTAL MANAGEMENT ZONE IMPACTS IN THE VICINITY OF THE
19
PROPOSED ALTERNATIVE ROUTES?
20
21
A.
None of the routes are located within the coastal management program boundary
as defined in 31 TAC § 503.1.
703
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
I
Q33.
2
3
Page 22 of 42
PLEASE DESCRIBE THE PERMITS OR APPROVALS THAT WILL BE
OBTAINED AS NECESSARY TO CONSTRUCT THE PROJECT.
A.
Permits will be obtained following the selection of a route by the PUCT. Below
4
is a list of permits that may be required for construction of the Project on any of
5
the routes:
6
•
Texas Department of Transportation ("TxDOT") permit(s) will be
7
required for crossing state-maintained roadways or using TxDOT ROW to
8
access the proposed Project (not yet obtained).
9
•
Depending on the location of structures, floodplain development permits
10
and road crossing permits might be required by the counties in which the
II
approved route is located (not yet obtained).
12
•
A Storm Water Pollution Prevention Plan ("SWPPP") will be prepared,
13
and a Notice of Intent will be submitted at least 48 hours prior to the
14
beginning of construction to the Texas Commission on Environmental
15
Quality under the Texas Pollutant Discharge Elimination System General
16
Permit (not yet obtained).
17
•
If necessary, a cultural resources survey plan will be developed and
18
clearance obtained from the Texas Historical Commission ("THC") for the
19
proposed Project (not yet obtained).
20
•
If the approved route triggers FAA criteria regarding proximity to airports,
21
Garland / Rusk will file a Notice of Construction form with the FAA (not
22
yet obtained).
23
•
Following the Commission's approval of this application, consultation
704
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 23 of 42
I
with the U.S. Army Corps of Engineers ("USACE") will
occur to
2
determine appropriate requirements, if any, under Section 404/Section 10
3
Permit criteria ( not yet obtained).
4
•
Following the Commission's approval of this application, consultation
5
with the U.S. Fish and Wildlife Service ("USFWS") will occur to
6
determine appropriate requirements under the Endangered Species Act, if
7
any (not yet obtained).
8
•
9
Following the Commission's approval of this application and following
consultation with the USACE and USFWS, consultation with the Texas
10
Parks and Wildlife Department ("TPWD") will occur (not yet obtained).
I1
•
Approval from the Federal Energy Regulatory Commission ("FERC") and
12
Sabine River Authority ("SRA") will be obtained to cross the SRA FERC
13
project boundary for the Toledo Bend Reservoir, if needed (not yet
14
obtained).
15
16
Q34.
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
17
THE NUMBER OF PARKS AND RECREATIONAL AREAS WITHIN 1,000
18
FEET
19
ALTERNATIVE ROUTES?
20
A.
OF THE CENTERLINES OF THE PROPOSED PRIMARY
Based on field reconnaissance and a review of the TPWD, Texas Natural
21
Resource Information System ("TNRIS"), and Environmental Systems Research
22
Institute, Inc. ("ESRI") digital data, there are two parks or recreational areas
23
crossed by two proposed routes: the George W. Pirtle Scout Reservation is
705
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 24 of 42
1
crossed by RP28 and land managed by the Sabine River Authority ("SRA") for
2
hunting ("Unit #630") is crossed by RP82. Both routes appear to cross in areas of
3
the property that are not developed and are heavily wooded.
4
(Northern) is the only proposed route that does not cross any parks and has no
5
identified park and recreation area within 1,000 ft.
6
have any park and recreation areas within 1,000 ft. (excluding the Unit #630
7
hunting area that is crossed).
8
recreation area located within 1,000 ft. of the route.
9
(Attachment 1) shows the park and recreation areas that are crossed by or within
10
1,000 ft. of the proposed routes. Most of the identified parks and recreation areas
11
that are not crossed but within 1,000 ft. are boat launches located along the Sabine
12
River or on Lake Murvaul. Figure 8-1 of the EA shows the parks and recreation
13
areas crossed by or within 1,000 ft. of the proposed routes. The route that crosses
14
the SRA lands may be subject to the provisions of Chapter 26 of the Parks and
15
Wildlife Code. Garland proposes to follow the same process employed in Docket
16
No. 38435 for addressing the requirements of Parks and
17
Chapter 26, including providing the notice required by Chapter 26 at the
18
appropriate time.
Route RP16
Route RP82 also does not
All of the remaining routes have one park and
Table 8-7 in the EA
Wildlife Code
706
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
1
Q35.
Page 25 of 42
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
2
POTENTIAL IMPACTS ON HISTORICAL AND AESTHETIC VALUES
3
FROM THE PROPOSED PRIMARY ALTERNATIVE ROUTES, INCLUDING
4
KNOWN CULTURAL RESOURCES SITES WITHIN 1,000 FEET OF THE
5
CENTERLINES OF THE PROPOSED ALTERNATIVE ROUTES?
6
A.
Although an on-the-ground cultural resources survey has not been conducted,
7
HPAs have been identified by cultural specialists along the proposed routes using
8
U.S. Geological Survey topographic maps.
9
identified as having a high probability for the occurrence of prehistoric sites and
10
include areas where the proposed Project crosses water, stream confluences,
11
drainages, alluvial terraces, wide floodplains, upland knolls, and areas where
12
lithics (workable stone) could be found.
13
57,740 ft. and 102,100 ft. of HPAs.
14
crossing a relatively small length of HPAs (RP4 and RP5 - 11.7-12.2 miles) and a
15
relatively high length across HPAs (RP8, RP16, and RP93 - 14.1-19.3 miles).
16
The Central routes are similarly split with RP28, RP41, and RP46 generally
17
crossing a relatively long length of HPAs (16.0-18.2 miles) and RPIO crossing
18
significantly shorter amounts of HPAs (12.9 miles).
19
routes are also split with both RP50 and RP53 crossing a relatively long amount
20
of HPAs (13.6-15.1 miles) and RP82 crossing the least amount of HPAs of all
21
proposed routes (10.9 miles).
HPAs are locations that are usually
The proposed routes cross between
The Northern routes are split between
Likewise, the Southern
22
Maps on file with the Texas Archaeological Laboratory and the THC
23
Archeological Sites Atlas were reviewed in an effort to identify known and
707
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 26 of 42
1
recorded archaeological sites and historic resources within 1,000 ft. of the
2
centerline of the proposed routes. Two Northern routes (RP16 and RP93) and one
3
Central route (RP46) each cross one known recorded cultural resource site.
4
Strategic pole placement and access road development could potentially avoid
5
impacts to these sites. The proposed routes would be located within 1,000 ft. of
6
between one and five recorded cultural sites.
7
RP8, RP 16, and RP93) would have between two and five recorded cultural sites
8
located within 1,000 ft. The Central routes (RP10, RP28, RP41, and RP46) would
9
have fewer than the Northern routes overall, with between one and two recorded
The Northern routes (RP4, RP5,
10
cultural sites located within 1,000 ft.
11
RP82) would have between one and four recorded cultural sites located within
12
1;000 ft.
13
distance to these resources. Once a route is approved by the PUCT, Garland will
14
work with the THC to determine what, if any, sites will be affected and what
15
mitigation efforts could be required to limit impacts.
The Southern routes (RP50, RP53, and
Table 8-10 in the EA lists these sites as well as the direction and
16
17
Q36.
WHAT ARE BURNS & MCDONNELL'S FINDINGS WITH RESPECT TO
18
IMPACTS ON ENVIRONMENTAL INTEGRITY FROM THE PROPOSED
19
ROUTES?
20
A.
The EA
addresses impacts on environmental integrity in Chapter 8.0.
21
Construction of the Project is not anticipated to have any significant adverse
22
effects on the physiographic or geologic features and resources in the area. The
708
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 27 of 42
1
Project may have some minimal and short-term impacts to soil, water, and
2
ecological resources.
3
Construction and operation of the transmission line would not result in any
4
significant impacts to the existing physiography.
5
only of tree and shrub removal. Any potential impact to topography would be
6
minimal and temporary in nature and would be from the use of heavy construction
7
equipment and excavation required for the construction of new foundations and
8
support structures.
9
disturbed areas (where possible) to limit potential impacts to land cover.
10
Land clearing would consist
All routes were designed to parallel existing ROW and
Because the majority of the study area is wooded, the majority of the
11
proposed routes have a significant amount of woodland within the ROW. The
12
proposed routes cross from 712.9 to 768.8 acres of woodland within the proposed
13
ROWs. The Northern Routes (RP4, RP5, RP8, RP 16, and RP93) generally have
14
the least amount of woodland within the ROW with a range of 712.9-732.6 acres.
15
The Southern Routes (RP50, RP53, and RP82) have a generally higher amount of
16
woodland within the ROW with a range of 731.6-759.4 acres. The Central Routes
17
(RP 10, RP28, RP41, and RP46) generally have the largest amount of woodland
18
within the ROW with a range of 726.6-768.8 acres. Route RP93 (Northern route)
19
would have the least amount of woodland within the ROW, and Route RP41
20
(Central route) would have the greatest amount of woodland within the ROW.
21
None of the proposed routes cross any land designated by TPWD as rangeland.
22
Only two of the proposed routes cross land classified by TPWD as cultivated, and
23
these routes (RP50 and RP53) cross very little (0.3 acres).
709
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 28 of 42
1
The Project would result in temporary, minor impacts to the soils within
2
the ROW during construction activities; no significant impacts to soils are
3
anticipated along any of the proposed routes. The primary impacts to soils would
4
result from the use of heavy construction equipment and excavation required for
5
construction of new foundations and support structures. These activities would be
6
temporary in nature but could cause soil compaction, ruts, or tracks from vehicle
7
movement, and mixing of the soil profile. Although the TPWD data indicated the
8
presence of very little cropland in the area, all of the proposed routes traverse
9
soils that are considered by the U.S. Department of Agriculture ("USDA") as
10
prime farmland.
11
prime farmland soils are anticipated to be minor and occur only at the base of
12
transmission line structures.
13
cause a conversion of farmland because the land can still be used after
14
construction.
15
Aside from potential construction-related erosion, impacts to
Transmission lines are typically not considered to
During construction of the proposed transmission line, some erosion could
16
occur within the cleared ROW, resulting in localized increases in soil loss and
17
perhaps sedimentation of area streams.
18
SWPPP and applicable permits will be prepared and obtained prior to any soil
19
disturbance.
To limit erosion and sedimentation, a
20
Potential hydrology impacts along the proposed routes were considered
21
and evaluated by the number of streams and rivers crossed by each route, the
22
number of Ecologically Significant Stream Segments ("ESSS") crossed, and the
23
length of streams parallel to the routes (within 100 ft.).
710
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 29 of 42
1
The Sabine River has been designated as an ESSS between the Toledo
2
Bend Reservoir and the Rusk/Panola County line. The only proposed route that
3
does not cross an ESSS is Route RP82, as this route crosses the Toledo Bend
4
Reservoir instead.
5
narrow enough that the transmission line could be built to span these water
6
features. Garland and Rusk will also implement a SWPPP and obtain associated
7
permits prior to any soil disturbance to reduce the potential for impacting the
8
water quality of streams during construction.
9
Both the Sabine River and the Toledo Bend Reservoir are
In general, the Northern Routes RP4, RP5, and RP8 cross the fewest
10
streams and rivers, from 83 (Route RP5) to 86 (Routes RP4). The other northern
11
routes, Routes RP16 and RP93, cross more streams with 100 and 93 streams
12
crossed, respectively.
13
between 94 and 100 streams. The Central Routes (RP10, RP28, RP41, and RP46)
14
cross the most streams with between 98 and 107 streams crossed. In general, the
15
The Southern Routes (RP50, RP53, and RP82) cross
Northern routes (RP4, RP5, RP8, RP 16, and RP93) have the shortest length
16
parallel to streams and rivers, ranging from 7,910-10,300 ft. The Central routes
17
(RP 10, RP28, RP4 1, and RP46) are parallel to streams and rivers the most with a
18
length between 13,590 and 17,260 ft. The Southern routes (RP50, RP53, and
19
20
RP82) have a length parallel to streams and rivers that is slightly shorter than the
Central routes, with a length parallel between 11,740 and 14,810 ft.
21
Construction and operation of the Project would not significantly impact
22
surface water features along the proposed transmission line. Short-term, minor
23
water quality impacts may occur during the construction of the proposed Project.
711
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 30 of 42
1
Such impacts would be associated with soils from disturbed areas being
2
transported into adjacent surface waters during storm events.
3
measures will be taken to reduce these impacts. To the extent required, Garland
4
and Rusk would obtain the appropriate permits from the USACE for any work
5
that crosses streams and rivers.
6
Appropriate
Impacts to groundwater and aquifers are not expected to occur from
7
construction of the proposed Project.
8
construction for the proper control and handling of any petroleum products or
9
other chemicals that may be needed during construction. Additionally, no mobile
10
irrigation systems were identified which would be impacted by any of the
1l
proposed routes.
Precautions will be taken during
12
If structures of the approved route were to be located in a Federal
13
Emergency Management Agency ("FEMA")-designated 100-year floodplain, then
14
planning, structure siting, engineering design, and any necessary permitting would
15
help mitigate construction activities impacting flood channels, and, therefore, the
16
Project should not significantly affect flooding.
17
Construction and operation of the Project would result in the loss of some
18
vegetation within the transmission line ROW due to clearing. The majority of the
19
vegetation that would be impacted by the proposed Project consists of pine
20
hardwood forests and young forests/grassland. Additionally, the vegetation cover
21
along the Sabine River is classified as willow oak-water oak-blackgum forests,
22
and all of the proposed routes would cross and require some clearing of
23
vegetation within this cover type. Generally, clearing in these areas would be to
712
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 31 of 42
1
provide access for construction and maintenance equipment, and to prevent
2
vegetation from growing tall enough to interfere with the lines.
3
proposed routes were designed to parallel existing ROW and extend through
4
disturbed areas to minimize potential impacts to vegetation.
Where possible,
5
Potential impacts to threatened and endangered plant species were
6
determined by reviewing data from the Texas Natural Diversity Database
7
("TXNDD"), maintained by the TPWD, written correspondence with the USFWS
8
and TPWD personnel, and potential habitat within the study area. No impacts to
9
threatened or endangered plant species are expected. The USFWS database does
10
list the potential for one threatened plant species to occur within Rusk County;
11
however, it is unlikely to occur within the study area.
12
by the PUCT, detailed environmental surveys will be conducted along the
13
proposed transmission line to identify potential habitat and/or endangered plant
14
species. If encountered, Garland and Rusk will coordinate with both the USFWS
15
and TPWD, as needed.
16
Upon approval of a route
The potential impacts to wetlands were determined based on a review of
17
aerial
18
topographic maps. The amount of forested/scrub-shrub wetlands within the ROW
19
of the proposed routes ranges from 22.8 acres (Route RP5, North) to 123.7 acres
20
(Route RP28, Central). In general, the Northern routes are split between a low
21
(RP4, RP5, and RP8) and moderate (RP16 and RP93) amount of forested/scrub-
22
shrub wetlands within the ROW. The three Northern routes (RP4, RPS, and RP8)
23
have the least amount of forested/scrub-shrub wetlands impacts compared with all
photography,
USFWS maps, USDA NAIP infrared imagery, and
713
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 32 of 42
1
the other proposed routes. The Central routes are split between a moderate (RP41
2
and RP46) and high (RPIO and RP28) amount of forested/scrub-shrub wetlands
3
within the ROW. The Southern routes are split between a low (RP82) and a
4
moderate (RP50 and RP53) amount of forested/scrub-shrub wetlands within the
5
ROW. The amount of riverine and emergent wetlands within the ROW of the
6
proposed routes ranges from 0.6 acre (Route RP82, South) to 5.1 acres (Routes
7
RP10 and RP28, Central). In general, the Southern routes (Routes RP50, RP53,
8
and RP82) cross the least amounts of riverine and emergent wetlands (less than
9
1 acre). The Northern routes (RP4, RP5, RP8, RP16, and RP93) cross a moderate
10
amount of riverine and emergent wetlands (1.7-3.1 acres).
11
(RP41 and RP46) cross approximately 3.1 acres of riverine and emergent
12
wetlands, while the remaining two Central routes (RP 10 and RP28) cross the most
13
(approximately 5.1 acres).
14
routes ranges from 270 ft. (Route RP28, Central) to 1,090 ft. (Route RP8, North).
15
The Central routes (RP 10, RP28, RP41, and RP46) generally have the least length
16
across open water, with a range of 270 to 630 ft. of open water crossed. The
17
Northern routes (RP4, RP5, RP8, RP16, and RP93) in general have the highest
18
amount of open water crossed, ranging from 730-1,090 feet of open water
19
crossed.
20
moderate impact, ranging from 330-710 ft. of open water crossed.
Two Central routes
The amount of open water crossed by the proposed
The Southern routes (RP50, RP53, and RP82) have a comparatively
21
To limit impacts to wetland areas, efforts were first made to identify
22
routes that crossed as few wetlands as feasible, and the approved route will be
23
designed to avoid or span wetland areas to the extent possible. Additionally, the
714
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 33 of 42
1
proposed routes were aligned parallel to existing ROW and through disturbed
2
areas (where possible) to limit potential impacts to wetlands. Upon approval of a
3
final route by the PUCT, detailed environmental surveys will be conducted along
4
the proposed transmission line to identify jurisdictional waters of the United
5
States. Garland and Rusk will obtain the appropriate permits from the USACE
6
for work within wetlands.
7
Construction and operation of the transmission line could result in some
8
temporary adverse impacts to wildlife, primarily from the removal of large trees
9
within or near the proposed Project that could provide feeding, shelter, or nesting
10
habitat for some species. Impacts to most species would be temporary and short-
11
term during construction and would consist primarily of displacement and
12
disturbance.
13
could be directly impacted, and movements between segmented habitats could be
14
temporarily impeded due to noise and human presence.
15
disturbance could occur during future maintenance of the transmission line. To
16
the extent possible, waterways will be spanned or avoided to limit impacts to
17
aquatic species. Proposed routes were designed to parallel existing ROWs to the
18
extent possible to limit potential impacts to wildlife.
Some less-mobile species occurring along the transmission line
Additional temporary
19
Potential impacts to threatened and endangered animal species were
20
determined by reviewing data from the TXNDD, maintained by TPWD;
21
correspondence with both USFWS and TPWD personnel; and reviewing aerial
22
photography to determine potential habitat for threatened and endangered species
23
likely to occur within the study area. The amount of threatened and endangered
715
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 34 of 42
I
species habitat crossed by the proposed routes (determined by the length through
2
TXNDD elemental occurrences GIS data) ranges from 0 ft. to 22,910 ft. The
3
Northern routes (RP4, RP5, RP8, RP16, and RP93) and one Central Route (RP10)
4
do not cross any threatened and endangered species habitat.
5
Central routes (RP28, RP41, and RP46) and two Southern routes (RP50 and
6
RP53) each cross approximately 13,330 ft. of threatened and endangered species
7
habitat.
8
threatened and endangered species habitat, with 22,910 ft.
9
route crosses an area identified by TPWD as containing a previously identified
10
rookery. It is possible this route would not be able to meet the recommendation
I1
of TPWD to avoid clearing within 300 meters of a heronry. Once a route is
12
approved by the PUCT, Garland and Rusk will coordinate with USFWS and
13
The remaining
The remaining Southern route (RP82) crosses significantly more
Additionally, this
TPWD to avoid impacts to threatened and endangered animal species along the
14
approved route.
15
identified habitat will be reported to both USFWS and TPWD.
Detailed surveys will also be completed, if required, and any
16
17
18
V.
Q37.
ADDITIONAL COMMISSION ROUTING CONSIDERATIONS
HOW HAS BURNS & MCDONNELL'S ANALYSIS CONSIDERED SUCH
19
FACTORS AS 1) USE AND PARALLELING OF EXISTING COMPATIBLE
20
ROW, 2) USE OF VACANT POSITIONS ON EXISTING MULTIPLE
21
CIRCUIT TRANSMISSION LINES, AND 3) USE OF PROPERTY
22
BOUNDARIES OR OTHER NATURAL OR CULTURAL FEATURES?
23
A.
In consideration of, and in compliance with 16 TAC § 25.101(b)(3)(B), Burns &
716
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 35 of 42
1
McDonnell's route delineation and route evaluation process considered utilizing
2
and paralleling existing compatible ROW and property boundaries where
3
practical and reasonable. In general, all of the proposed routes parallel existing
4
corridors (including apparent property boundaries) for a portion of their length.
5
Due to Garland, Rusk, and the PUCT's preference not to parallel pipeline
6
corridors and the limited amount of other suitable utility corridors between the
7
two proposed switching stations, identifying potential alternatives that parallel
8
existing corridors for a substantial length (more than 50% of their length) was not
9
possible for this Project.
10
The proposed routes range from 36.9 to 39.8 miles in total length, with a
11
range of approximately 16.0 to 38.5 percent of their total length parallel to
12
existing corridors (i.e., existing transmission lines, roads, and apparent property
13
boundaries). The Northern routes (RP4, RP5, RP8, RP 16 and RP93) are generally
14
the shortest routes (36.9-38.0 miles), and they parallel existing transmission lines
15
(9.8-25.7 percent) for a greater percentage of their length, compared to the other
16
proposed routes. RP10 is the only other route that parallels existing transmission
17
lines (11.1 percent parallel).
18
corridors, including roads and apparent property lines) more (23.4-38.5 percent)
19
than most of the other Central and Southern proposed routes (16.0-24.4 percent).
20
For the Central and Southern routes, the majority of existing corridor paralleled is
21
apparent property lines, rather than an existing utility or road.
Additionally, the Northern routes parallel all
22
By paralleling existing corridors, potential impacts to property,
23
community values and community resources, and viewsheds are typically limited
717
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 36 of 42
1
due to the already disturbed nature of the area crossed by the existing
2
facility/corridor. Paralleling existing corridors is therefore normally considered
3
preferable to creating a completely new corridor.
4
Natural or cultural features such as areas of concentrated residential
5
development, wetlands, floodplains, cemeteries, parks and recreation areas,
6
airports or airstrips, and center-pivot irrigation were avoided where reasonable
7
and feasible. The use of vacant positions on existing multiple circuit transmission
8
lines was not an option for the Project for several reasons. First, there were few
9
existing transmission lines that extend in the same general direction as this
10
Project, but even for those lines that could be used for short sections, a review of
11
Google Earth street view imagery of the lines confirmed that there are no vacant
12
positions on those existing lines. In addition, this Project is being proposed as a
13
double-circuit line, so there would need to be two vacant positions on an existing
14
line for this to be feasible. Triple-circuit lines are rare, and there were also no
15
existing lines in the study area built with two available vacant positions.
16
17
Q38.
18
19
HAVE AN ADEQUATE NUMBER OF ALTERNATIVE ROUTES BEEN
FORMULATED TO CONDUCT A PROPER EVALUATION?
A.
Yes. Considering the distance between the Project end points and the nature of
20
the study area, I believe that the 12 proposed routes provide an adequate number
21
of alternative routes for evaluation.
22
were collected for each segment, and all of the segments were used to develop the
23
proposed routes filed in the application. I believe the 12 proposed routes filed in
Data for the environmental/land use criteria
718
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 37 of 42
I
the
2
geographically varied alternative routes for an approximately 37-40 mile long
3
transmission line. In addition, the Commission can select a route made up of any
4
combination of proposed segments.
application
represent
an
adequate
number of reasonable, viable,
5
6
Q39.
7
8
DO ALTERNATIVE ROUTE CONFIGURATIONS EXIST THAT WOULD
HAVE LESS IMPACT ON LANDOWNERS?
A.
No, not based on information gathered and evaluated by Burns & McDonnell.
9
The routing process involved the delineation of numerous routes, as depicted in
10
Figures 3-3, 3-4, 3-5, and 8-1 of the EA. Information on community values,
11
habitable structures, parks and recreation areas, archaeological and historic sites,
12
aesthetics, and environmental integrity is presented for the alternative routes in
13
the EA. Unfortunately, it is not possible to identify a route that has absolutely no
14
impact to landowners. While many landowners affected by the proposed routes
15
likely feel that there are other alternatives that would lessen the impact on their
16
property, those alternatives necessarily impact other landowners. However, Burns
17
& McDonnell's studies indicate that, on balance, the proposed routes limit
18
adverse impacts on affected landowners to the extent practicable. The routes also
19
limit adverse impacts on the natural environment and social resources in the area.
20
Based on information gathered and evaluated by Burns & McDonnell, additional
21
feasible alternative route configurations
22
landowners.
would not have less impact on
719
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
I
Q40.
Page 38 of 42
DO YOU BELIEVE THE CONCEPT OF "COMMUNITY VALUES" HAS
2
BEEN ADEQUATELY ADDRESSED BY COMPILATION OF DATA BY
3
BURNS & MCDONNELL, INCLUDING THE DATA THAT HAS BEEN
4
RECEIVED FROM THE AGENCIES AND THE PUBLIC?
5
A.
Yes. The term "community values" is included as a factor for the consideration
6
of transmission line certification under PURA § 37.056(c)(4), although the term
7
has not been specifically defined for regulatory purposes by the Commission. In
8
Burns & McDonnell's experience, the PUCT typically includes the following
9
within its discussions of community values:
10
•
11
Shared appreciation of an area or other natural or social resources by a
national, regional or local community;
12
•
AM, FM, microwave, and other electronic installations in the area;
13
•
Approvals or permits required from governmental agencies;
14
•
Comments received from community leaders and the public;
15
•
Description of the area traversed;
16
•
FAA-registered airstrips, private airstrips, and heliports in the area;
17
•
Habitable structures within 500 ft. of the Project centerline;
18
•
Irrigated pasture or croplands using center-pivot or other traveling
19
20
irrigation systems; and,
•
Public meeting or public open-house participation.
21
Burns & McDonnell also evaluated the Project for community resources that may
22
be important to a particular community, such as parks or recreational areas,
720
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 39 of 42
I
schools, cemeteries, historical and archaeological sites, or scenic vistas within the
2
study area.
3
Bums & McDonnell's consideration of the Project's effect on "community
4
values," which is described in Chapter 8.0 of the EA, indicates that the Project
5
would not result in the disruption or preemption of any recreational activities or
6
shared appreciation of an area or other natural or human resource, but could have
7
temporary and permanent impacts on visual aesthetics.
8
corridors, potential impacts to property, community values and community
9
resources, and viewsheds are typically limited due to the already disturbed nature
10
of the area crossed by the existing facility/corridor.
11
By paralleling existing
The proposed routes range
from approximately 16.0 to 38.5 percent of their total length parallel to existing
12
corridors
13
boundaries) to help limit impacts to community resources as well.
14
(i.e.,
existing transmission lines, roads, and apparent
property
Burns & McDonnell's studies adequately address the requirements of
15
PURA and PUCT Substantive Rules regarding consideration of the effects of the
16
proposed transmission line on "community values."
17
18
Q41.
19
20
ARE YOU FAMILIAR WITH THE COMMISSION'S POLICY OF "PRUDENT
AVOIDANCE?"
A.
Yes. 16 TAC § 25.101(a)(4) defines the term "prudent avoidance" to mean "[t]he
21
limiting of exposures to electric and magnetic fields that can be avoided with
22
reasonable investments of money and effort."
721
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
I
Q42.
2
4
DO YOU BELIEVE THE ROUTES CONSIDERED BY BURNS &
MCDONNELL
,3
Page 40 of 42
AND THE APPLICANT CONFORM TO THE
COMMISSION'S POLICY OF PRUDENT AVOIDANCE?
A.
Yes.
One of the more important measures of potential land use impacts is the
5
number of habitable structures located in the vicinity of each route.
6
McDonnell determined the number, distance, and direction of habitable structures
7
located within 500 ft. of the centerline of each route through interpretation of
8
aerial photography and verification during reconnaissance surveys along public
9
roads, where possible.
Burns &
Burns & McDonnell, to the extent reasonable and in
10
accordance with the policy of prudent avoidance, attempted to avoid habitable
11
structures in the routing of the preliminary, primary, and proposed routes.
12
The number of habitable structures located within 500 ft. of the proposed
13
route centerlines ranges between 13 and 27.
14
fewest habitable structures within 500 ft. of the centerline ( 13 structures).
15
other two Southern routes ( RP50 and RP82) have between 21 and 24 structures
16
within 500 ft. The Central routes (RP 10, RP28, RP41, and RP46) followed Route
17
RP53 with 15 to 20 structures within 500 ft., while the Northern routes (RP4,
18
RP5, RP8, RP 16, and RP93) had the most structures within 500 ft. (between 21
19
and 27).
20
structures within 500 ft., because they parallel existing transmission lines for
21
more of their length than the other proposed routes, some of these structures are
22
already located close to an existing line, thereby limiting the overall impact of
23
these proposed routes on the habitable structures. Figure 8-1 (map pocket) shows
Route RP53 ( Southern) has the
The
While the Northern routes have the greatest number of habitable
722
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 41 of 42
1
the location of each habitable structure, and Table 8-6 lists the types of habitable
2
structure, the direction and distance from the closest segment component of each
3
proposed route, and the unique identification number assigned to each habitable
4
structure depicted in Figure 8-1. The routes considered in the EA conform to the
5
Commission's policy of prudent avoidance in that they reflect reasonable
6
investments of money and effort to limit exposure to electric and magnetic fields.
7
8
Q43.
9
MITIGATION
10
11
HAS BURNS & MCDONNELL REVIEWED AND CONSIDERED CERTAIN
MEASURES FOR THIS PROJECT TO DECREASE
POTENTIAL IMPACTS FROM THE PROJECT?
A.
Yes, it has. Some mitigation measures are described in Chapter 8.0 of the EA.
12
The primary form of mitigation during the routing phase of the Project was
13
avoidance, followed by minimization of potential impacts to resources of concern.
14
When resources could not be avoided through the routing process, coordination
15
with the appropriate federal, state, and local agencies during the permitting phase
16
of the Project will result in additional mitigation measures required by the
17
agencies to minimize impacts. These measures could include, but would not be
18
limited to, strategic pole placement during design, implementing erosion control
19
Best Management Practices such as silt fences and barriers during construction,
20
mitigation bank payments and/or habitat enhancements, and adjusting clearing
21
and construction schedules to avoid disturbance during critical periods.
22
Mitigation measures recommended and required by the agencies as part of the
723
Docket No. 45624
City of Garland
Direct Testimony of Kristi Wise
Page 42 of 42
1
permitting process will be implemented by Garland and Rusk to limit the impacts
2
of the Project to the extent practicable.
3
4
Q44.
5
6
WHAT ARE BURNS & MCDONNELL'S CONCLUSIONS REGARDING
THESE MITIGATION MEASURES?
A.
7
Mitigation measures should serve to reduce and mitigate the potential adverse
effects of construction and operation of the proposed Project.
8
9
VI.
SUMMARY AND CONCLUSION
10
Q45.
PLEASE SUMMARIZE YOUR TESTIMONY.
11
A.
In this application, Garland proposes to construct a double-circuit 345-kV
12
transmission line from the new Rusk Switching Station to the new Panola
13
Switching Station. Burns & McDonnell and Garland have selected 12 proposed
14
routes for the Project. In Bums & McDonnell's opinion, all proposed route
15
alternatives are viable, feasible, and minimize environmental impacts to the extent
16
practicable and satisfy the criteria specified in PURA and the PUCT's Substantive
17
Rules for transmission line siting. My testimony and the EA address the differing
18
extent to which the proposed alternative routes satisfy such requirements.
19
20
Q46.
DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
21
A.
Yes, it does.
724
Exhibit KW-1
PUC Docket No. 45624
Page 1 of 6
KRISTI K. WISE, PMP
Project Manager
Kristi Wise is a Project Management Professionalcertified (PMP) project manager and biologist at
Burns and McDonnell. She specializes in project
and program management, transmission line
routing and permitting, public involvement, and
wildlife biology, including endangered species'
habitat assessment.
TRANSMISSION LINES
Kristi has successfully managed more than 48 projects, totaling more than
5,600 miles of transmission lines in 19 different states. Projects ranged in voltage from 69 kilovolt (kV) to 765 kV and in
mileage from less than one mile to approximately 1,500 miles. Kristi has managed budgets ranging from less than $100,000
to over $10 million and, as a certified PMP professional, has managed and integrated project scope, cost, schedule, quality,
stakeholders, and risks, as well as managing project staff across various offices and overseeing procurement activities. Ms.
Wise's project management experience includes monitoring of cost and schedule performance using earned value
measurements (CPI and SPI)
Kristi has prepared written testimony, rebuttal testimony, and/or testified live before the North Carolina Utilities Commission
seven times, in addition to the South Carolina Public Service Commission, the Kansas Corporation Commission twice, and
the Texas Public Utility Commission. Kristi has coordinated and participated in numerous public open house meetings,
several with an attendance of more than 500 people, and she has managed both permitting and right-of-way tasks for multiple
projects. Permits have included: Section 404/401 water quality permits; Section 10 river crossing permits; threatened and
endangered species surveys, clearances, and mitigation management for the bald eagle, Indiana bat, northern long-eared bat,
lesser and greater prairie chickens, whooping cranes, and others; cultural resources and Section 106 clearances; National
Pollutant Discharge Elimination System (NPDES) and Storm Water Pollution Prevention Plan permits; road and railroad
crossing permits; and various state and local permits and clearances.
Kristi has investigated social, environmental, and engineering constraints for multiple transmission line routing projects.
Issues have included investigating the feasibility of underground construction, restricted approach surfaces at airports and
airstrips, sensitive species habitat, wetlands, residential growth areas and developments, forest and agricultural impacts,
cultural resources, crossings of state and federally owned lands, and other locally significant impacts. Kristi managed and
evaluated collected data to identify the most socially and environmentally acceptable routes, and prepared reports to
summarize the methodology and results for the client and the public.
Public participation programs involved coordinating and preparing displays and documents for community advisory councils
and public open houses. She has addressed a variety of questions and issues posed by the public and local agency personnel
at project open houses and agency workshops. Kristi has also created questionnaires to elicit public concerns and compiled
the responses for use in the routing analysis.
Kristi is the coordinator and a principal instructor for Burns & McDonnell's training seminar on transmission line routing and
public involvement for utilities. She also coauthored Burns & McDonnell's Transmission Line Routing Manual. She has
published articles on environmental issues for underground transmission lines in the International Right-of-Way
^
Exhibit KW-1
PUC Docket No. 45624
Page 2 of 6
Association's Right of Way Magazine and Florida's Relay magazine. Kristi also wrote an article on the use of new
technologies to help identify and evaluate transmission line routes in Transmission and Distribution World.
Below is a description of selected transmission line projects Kristi has managed or supported across the country.
Craggy to Enka 230-kilovolt (kV) Transmission Line Project ( Duke Energy
Progress
Asheville, North Carolina 1 2014
Project director directing the routing and public involvement activities for this 10- to 20-mile 230-kV transmission line
project connecting Duke Energy Progress' existing Craggy Substation with their existing Enka Substation. The project is
located in a highly developed area in Asheville, North Carolina. The routing is made even more challenging by the eminent
domain law in North Carolina that prohibits Duke Energy Progress from condemning yards and gardens. As a result, the
project may require extending the project about twice the length to avoid the largest concentrations of development, causing
the potential to extend into mountainous and wooded terrain. Duke Energy Progress is also investigating the possibility of
rebuilding an existing line within a very restricted-width right-of-way that extends through heavy residential development
and may result in engineering challenges to avoid having homes within the proposed right-of-way.
Foothills to Asheville 230-kilovolt (kV) Transmission Line Project I Duke Energy
Progress
Southwestern North Carolina and Northwestern South Carolina 1 2014
Project director directing the routing and public involvement activities for this 45-mile 230-kV transmission line project
connecting Duke Energy Progress' existing Asheville Substation with a new Foothills Substation located in South Carolina,
near Campobello. The project extends through mountainous terrain containing large federal, state, and local easements and
lands with protected species and other concerns, as well as through a portion of the cities of Hendersonville and Asheville.
The Asheville Substation is located in a highly developed area and just north of the Asheville Airport. In addition to
environmental concerns and development, there are many cultural resources located throughout the study area, which present
additional challenges. The project is also of significant concern to the public, as it runs through horse farms, areas of visual
concern, and high-value subdivisions. The public involvement process resulted in more than 3,000 public comments.
Greentown to Reynolds 765-kilovolt (kV) Transmission Line Project I Northern
Indiana Public Service Company (NIPSCO)/Pioneer
North Central Indiana 12013-2015
Project manager for the routing, public involvement, and permitting activities for this 70-mile 765-kV transmission line
project connecting the Reynolds and Greentown substations in north central Indiana. The project is jointly managed by
NIPSCO and Pioneer (Duke Energy and American Electric Power). The project scope included route development and
selection, advisory group meetings, two rounds of open houses, website/hotline setup and management, implementation of
OneTouchPM, and other public input activities, as well as detailed wetlands, protected species, and cultural surveys and
permit acquisition. The project budget exceeded $2 million and included detailed scheduling tasks, earned value reporting,
cash flow estimating, and other project controls.
A4
Exhibit KW-1
PUC Docket No. 45624
Page 3 of 6
Reynolds to Topeka 345-kilovolt (kV) Transmission Line Project ( Northern Indiana
Public Service Company
North Central Indiana 1 2012-2014
Project manager for the routing, public involvement, permitting, right-of-way acquisition, and preliminary substation and
transmission line design activities for this 100-mile 345-kV transmission line project connecting the Reynolds, Burr Oak, and
Hiple substations in north central Indiana. The project included route identification, analysis, and selection; public
involvement activities, such as advisory group meetings; two rounds of open houses; website/hotline setup and management;
implementation of OneTouchPM, and other public input activities; detailed environmental surveys for wetlands, protected
species, and cultural resources and acquisition of necessary permits; and right-of-way acquisition for more than 600 parcels.
The project budget exceeded $8 million and included detailed scheduling tasks, earned value reporting, and other project
controls. The overall agreement managed by Kristi exceeded $10 million.
Dowling Substation and 138-kilovolt (kV)/345-kV Transmission Line Project I
FirstEnergy
Perrysburg, Ohio 1 2012-2013
Project manager for the routing and substation siting for this project near Perrysburg, Ohio. The project involved siting and
construction of a new 138-kV and 345-kV substation and new 138-kV and 345-kV transmission line connections, which
totaled approximately 5 miles through high-quality cropland outside of Perrysburg. Kristi directed the preparation of Letters
of Notification to the Ohio Power Siting Board for approval of the proposed substation and transmission lines. She also
prepared exhibits for and attended a public informational meeting.
Northern Ohio Corridor Study I FirstEnergy (FE)
Northern Ohio 12012
Project manager for the investigation of more than 30 different potential routing corridors, totaling nearly 1,500 miles, for
new 345-kilovolt (kV) transmission lines in northern Ohio for FirstEnergy. Investigations included identifying appropriately
sized study areas to conduct the feasibility assessments, followed by documenting constraints and opportunities within each
study area, in case FE chose to construct a new 345-kV line between the proposed new or existing substations. The team
reviewed and evaluated the potential to expand existing substations, the feasibility of siting new substations in certain areas,
and the feasibility of constructing a transmission line in the area. The study involved documenting cities; linear facilities,
such as highways and transmission lines; large developments; cultural resources; parks and recreation areas; land uses; and
other resources that would affect the potential for constructing the new line. This study ultimately resulted in a feasibility
assessment by the team, which was led by Kristi.
Bowers to Howard 230-kilovolt (kV) Transmission Line Project I Southwestern
Public Service (SPS) Company/Xcel Energy
Texas Panhandle ( 2011-2013
Project manager
for the routing and public involvement activities for this 20-mile 230-kV project in the panhandle of Texas.
Several other transmission lines have been proposed and constructed in the area, so landowners and agencies are sensitive to
additional construction. The project is within the estimated occupied range of the lesser prairie-chicken (LPC). Kristi and
team assisted SPS with the preparation of the application for a Certificate of Convenience and Necessity from the Texas
Public Utility Commission and prepared written testimony in support of the project. Following submittal of the application,
Kristi and team assisted SPS with assessing the potential impact of the project to the LPC.
A4
Exhibit KW-1
PUC Docket No. 45624
Page 4 of 6
Goodyear to MacVicar to 17th Street and Fairlawn 115-kilovolt (kV) Transmission
Line Project I Westar Energy
Topeka, Kansas 1 2011-2012
Project manager for this short 10-mile 115-kV project in Topeka, Kansas. Kristi managed the routing and public
involvement activities. Primary routing issues included finding routes through an urban, highly developed environment and
avoiding parks and recreation areas (such as the Gage Park zoo), cemeteries, commercial developments, and tightly-spaced
homes. A portion of the project also crossed the Kansas River and required a Section 10 permit from the U.S. Army Corps of
Engineers.
Central A to Central C to Sam Switch to Navarro 345-kilovolt Project I Lone Star
Transmission
Central Texas 1 2009-2010
Assistant project manager for this 300-mile project for Lone Star Transmission, a new transmission supplier in Texas. The
project was part of the Transmission Optimization Study for Competitive Renewable Energy Zones in Texas. Kristi
developed more than 1,000 miles of route alternatives, participated in open houses to gather public input, and analyzed the
routes according to the Texas Public Utility Commission's rules and requirements for an Application for a Certificate of
Convenience and Necessity, which was filed on May 24, 2010. Kristi also helped prepare responses to Requests for
Information during the discovery phase of the project, and attended the week-long hearings and provided testimony support.
Gray to Tesla, Gray to White Deer, and Silverton to Tesla 345-kilovolt Project (
Cross Texas Transmission
Texas Panhandle 1 2009
Assistant project manager for budgets and overall project completion activities for these three projects totaling
approximately 200 miles in the Texas Panhandle. Routes were developed and analyzed according to the requirements for
Competitive Renewable Energy Zones projects in Texas by the Texas Public Utilities Commission. Kristi participated in
open houses for the projects. Unlike most transmission siting projects, the majority of the public potentially affected by these
transmission lines actually desired the line on their property to facilitate the siting of wind farms in the vicinity. The projects
also extended through potential habitat for the lesser prairie-chicken, a species unlisted at the time of the project but of
utmost concern to the wildlife agencies.
Viola to Medicine Lodge, Kansas to Woodward, Oklahoma 345-kilovolt (kV)
Prairie Wind Transmission (Westar Energy and American Electric Power)
South Central Kansas 1 2008-2011
Project manager for the routing and public involvement activities for this project. The project, as initially conceived in 2008,
was a 230-mile 765-kV project, but was redeveloped in 2010 to be a 345-kV line from Wichita, Kansas, to Spearville,
Kansas, and from Medicine Lodge, Kansas, south to Woodward, Oklahoma. Prairie Wind's portion of the revamped project
extended 110 miles from Wichita to Medicine Lodge and south from Medicine Lodge to the Oklahoma border. Primary
routing issues included minimizing impacts to residences, center-pivot irrigation systems, oil and gas wells, pumps and tanks,
lesser prairie-chicken habitat, and the environmentally sensitive Red Hills. A routing study was prepared to support Prairie
Wind Transmission's Application to the Kansas Corporation Commission (KCC) for a siting permit. Kristi also attended two
public hearings held by the KCC and testified on behalf of Prairie Wind Transmission at the technical hearing.
A
Exhibit KW-1
PUC Docket No. 45624
Page 5 of 6
Richmond to Fort Bragg Woodruff Street Project I Progress Energy Carolinas
Southern North Carolina 12007-2008
Project manager for the routing and public involvement efforts for this 70-mile 230-kV transmission line, which involved
crossing Fort Bragg, a military base in Fayetteville, North Carolina. The primary issues involving routing included working
with military personnel to identify a workable on-base route. The project would also have to avoid or minimize potential
impacts to the Lumber River, a state and federally designated Wild and Scenic River; state-owned lands, including Lumber
River State Park; dedicated and registered natural areas; natural heritage sites; Nature Conservancy lands; U.S. Fish and
Wildlife Service Safe Harbor lands; wetlands; private and public airstrips and airports; foraging and nesting habitat of the
red-cockaded woodpecker and other sensitive species; and concentrations of residential development. The project required
the preparation of an application for a Certificate of Environmental Compatibility and Public Convenience and Necessity for
the North Carolina Utilities Commission. Kristi also testified on behalf of Progress Energy at a technical hearing in Raleigh.
Harris to Durham 230-kilovolt (kV) Project I Progress Energy Carolinas
Raleigh, Cary, and Durham, North Carolina 1 2007
Project manager for this three-phase project that involved developing a defensible rationale for rebuilding an existing 115kV line to 230-kVfor approximately six miles between Apex and Cary; rationale for using an alignment for another eight
miles from Cary to Research Triangle Park (RTP), where no existing line had been constructed but easements had been
negotiated; and developing new routes for another two sections of the project, from the Harris Nuclear Plant to Apex and
from RTP into Durham. The project involved updating the information initially collected when the 115-kV line was routed,
providing a cost estimate for placing the line underground along existing lines, and submitting the information to the North
Carolina Utilities Commission. The primary issues related to the development of new routes between RTP and the Durham
Substation were the concentration of existing and new developments (both commercial and residential) covering the project
area, the presence of the Raleigh Durham International Airport and associated lands, avoidance of state parks and lands
designated as "open space," and the development requirements within the RTP.
Rose Hill to Sooner Project I Westar Energy and Oklahoma Gas & Electric
Company
South-central Kansas and North-Central Oklahoma 12007
Project manager for the route development, public involvement program, route analysis, and documentation for this 80-mile
project. Documentation for the Kansas portion of the project was completed to satisfy the requirements for review by the
Kansas Corporation Commission. The Oklahoma portion of the project did not require oversight by a utility commission.
Primary issues involved avoiding concentrations of residential and commercial development, assessing potential impacts to
Native American lands in Oklahoma, and minimizing impacts to agricultural operations.
Central Missouri Generation and Transmission Project I Associated Electric
Cooperative
Central and Northwestern Missouri I 2005-2006
Project manager for the transmission line routing portion of this project. Kristi identified and analyzed macro-level corridors,
completed a routing study, and coordinated National Environmental Policy Act-driven tasks with the Rural Utilities Service,
as well as routing efforts with NW and Central Electric Cooperatives for this 345-kilovolt transmission line associated with a
proposed coal-fired power plant. Corridors and routes were identified for two proposed power plant sites with four different
interconnections. Approximately 250 miles of corridors were developed. Kristi was also involved in the conceptualization
and development of materials for project scoping meetings. Primary issues concerning the transmission line involved impacts
to homes and potential collisions of waterfowl using a nearby federal refuge.
A
I9
Exhibit KW-1
PUC Docket No. 45624
Page 6 of 6
Middletown to Norwalk Project I Northeast Utilities Service Company (NUSCO)
Southwestern Connecticut 1 2002-2005
Assistant project manager who assisted with the development of routes, preparation of a Certificate of Environmental
Compatibility and Public Convenience and Necessity, and public involvement for this 70-mile, 345-kilovolt transmission
line, including overhead and underground construction in NUSCO. As proposed, approximately 25 miles of the transmission
line would be placed underground within local streets and highways. Kristi investigated alternative routes for both the
underground and overhead portions of the project, participated in multiple open houses held in each affected town, and
prepared text for the application documenting the investigation of available routes and the selection of the proposed
alternative. She also assisted Burns & McDonnell's Transmission and Distribution personnel with the preparation of design
documentation and drawings.
Arrowhead to Weston ^ Wisconsin Public Service and Minnesota Power
Northwestern Wisconsin 1999-2000
Principal investigator who assisted in the preparation of a routing application to the Public Service Commission for
Wisconsin Public Service and Minnesota Power for a 250-mile 345-kilovolt transmission line extending from Wausau,
Wisconsin, to Duluth, Minnesota. Kristi conducted extensive site surveys for residences and other sensitive features
potentially impacted by the proposed routes, and she also designed a database for the input, organization, and presentation of
an extensive amount of project data. She prepared aerial photographs, quadrangle maps, and floodplain maps for public
presentation, and contacted county officials for information regarding zoning, land use, and forest impacts.
A4
PUC DOCKET NO. 45624
APPLICATION OF THE CITY OF
GARLAND, TEXAS, FOR A
CERTIFICATE OF CONVENIENCE
AND NECESSITY FOR THE
PROPOSED RUSK TO PANOLA
DOUBLE-CIRCUIT 345-KV
TRANSMISSION LINE IN RUSK
AND PANOLA COUNTIES, TEXAS
§
§
§
§
§
§
§
§
BEFORE THE
PUBLIC UTILITY COMMISSION
OF TEXAS
DIRECT TESTIMONY
OF
CHRIS MCCALL
ON BEHALF OF
THE CITY OF GARLAND
FEBRUARY 25, 2016
731
CITY OF GARLAND
DIRECT TESTIMONY OF CHRIS MCCALL
TABLE OF CONTENTS
Page
1.
INTRODUCTION
I
if.
PURPOSE OF TESTIMONY
3
III.
PROJECT DESCRIPTION AND ESTIMATED SCHEDULE
4
IV.
CONDUCTOR AND STRUCTURE SELECTION
5
V.
PROJECT IMPACT ON RIGHT-OF-WAY, FACILITIES, AND OTHER
VI.
UTILITIES
7
ESTIMATED COST AND ENGINEERING OF THE PROPOSED
ROUTES
9
VII.
ALTERNATIVES CONSIDERED
10
VIII.
SUMMARY AND CONCLUSION
10
EXHIBITS
Exhibit CM-I
Estimated Cost Table
732
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
Page 1 of 11
I.
1
INTRODUCTION
2
Q1.
PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3
A.
My name is Chris McCall, P.E. I am a Project Manager for Burns & McDonnell
4
Engineering Inc.
5
City, MO 64114.
My current business address is 9400 Ward Parkway, Kansas
6
7
Q2.
BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY?
8
A.
I am a Project Manager for Burns & McDonnell Engineering Inc.
Q3.
PLEASE DESCRIBE YOUR JOB RESPONSIBILITIES, PARTICULARLY AS
9
10
11
12
THEY RELATE TO YOUR TESTIMONY IN THIS PROCEEDING.
A.
My responsibilities for project management include preparing cost estimates and
13
schedules for various project tasks as well as developing and managing contracts
14
and sub-consultants.
15
detailed design tasks of transmission line facilities. Major tasks performed under
16
my supervision include: transmission line design and structure spotting using the
17
PLS-CADD suite of software; conductor selection studies; insulator and hardware
18
design; grounding design; lightning performance studies; preparation of project
19
cost estimates; preparation of procurement and construction specifications;
20
preparation of Bills of Materials; and preparation of Issued for Construction
21
drawing packages.
I also manage engineering personnel responsible for the
733
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Q4.
2
3
Page 2 of 1 1
ARE YOU AND YOUR STAFF RESPONSIBLE FOR THE ENGINEERING
AND DESIGN OF THE PROJECT INVOLVED IN THIS PROCEEDING?
A.
Burns & McDonnell are principally responsible for creating preliminary plans and
4
exhibits, cost estimates, specifications for the overhead transmission lines of the
5
Rusk to Panola Transmission Line Project ("Project") as proposed by the City of
6
Garland, dba Garland Power & Light ( "Garland"), and Rusk Interconnection LLC
7
("Rusk"). An Engineering, Procurement and Construction ("EPC") firm will be
8
hired to perform the final engineering and design of the project. Our team will
9
provide engineering oversight on behalf of Garland and Rusk.
10
II
Q5.
12
13
PLEASE
DESCRIBE
YOUR EDUCATIONAL AND PROFESSIONAL
QUALIFICATIONS AND BUSINESS EXPERIENCE.
A.
I am a Professional Engineer in the states of Kansas, California, and Nevada with
14
a Bachelor Degree in Civil Engineering from Oklahoma State University. I
15
graduated in 2005. Since 2005 1 have worked for Burns & McDonnell as an
16
Assistant, Staff, and Senior Structural engineer within the electrical transmission
17
industry.
18
Transmission projects in the development of line configuration, structure design,
19
foundation design, and overall system design. From approximately 2011 to the
20
present I have also worked in Project Management for a number of transmission
21
design and construction projects.
From an engineering standpoint, I have mainly supported Overhead
734
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Q6.
2
3
Page 3 of 1 1
HAVE YOU PREVIOUSLY PERFORMED WORK RELATED TO
TRANSMISSION LINE ADMINISTRATIVE PROCEEDINGS?
A.
Yes, I have.
Q7.
HAVE YOU TESTIFIED PREVIOUSLY BEFORE THE PUBLIC UTILITY
4
5
6
7
COMMISSION OF TEXAS?
A.
No, I have not.
8
9
II.
PURPOSE OF TESTIMONY
10
Q8.
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
11
A.
I describe the engineering design plan for the Project's high voltage alternating
12
current ("AC") overhead transmission lines and the ability of this design to
13
maintain safe parameters following the minimum requirements of the National
14
Electric Safety Code ("NESC").
15
and cost for the Project, conductor and structure selection, and potential impacts
16
on right-of-way, facilities, and other utilities.
My testimony summarizes estimated schedule
17
18
Q9.
19
20
21
WHAT PORTIONS OF THE APPLICATION IN THIS DOCKET DO YOU
SPONSOR OR CO-SPONSOR?
A.
The preliminary transmission line design expectations including sections 4, 5, 6,
7, 8, 11, 13, 15 and 16 of the CCN Application Form.
735
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Q10.
Page 4 of 11
WERE YOUR TESTIMONY, AND THE INFORMATION YOU HAVE
2
IDENTIFIED
3
KNOWLEDGEABLE PERSONS UNDER YOUR SUPERVISION AND UPON
4
WHOSE EXPERTISE, JUDGMENT AND OPINIONS YOU RELY IN
5
PERFORMING YOUR DUTIES?
6
A.
7
AS SPONSORING, PREPARED BY YOU OR BY
Yes, my testimony was prepared by me and by knowledgeable persons under my
supervision.
8
9
Q1 1. IS THE INFORMATION THAT IS CONTAINED IN YOUR TESTIMONY
10
AND THAT YOU ARE SPONSORING TRUE AND CORRECT TO THE BEST
Il
OF YOUR KNOWLEDGE AND BELIEF?
12
A.
Yes, it is correct to the best of my knowledge and belief.
13
14
III.
PROJECT DESCRIPTION AND ESTIMATED SCHEDULE
15
Q12.
PLEASE DESCRIBE THE RUSK TO PANOLA TRANSMISSION PROJECT.
16
A.
The proposed Project is a double-circuit, 345-kilovolt ("kV") alternating current
17
("AC") electrical transmission line between the new Rusk Switching Station to be
18
located in Rusk County, Texas, and the new Panola Switching Station to be
19
located in eastern Panola County, Texas.
20
required to provide a physical interconnection with the Southern Cross
21
Transmission Line ("SCT") project as directed by the Federal Energy Regulatory
22
Commission ("FERC") under the authority of the Federal Power Act. The design
23
and operating voltage rating for the proposed transmission line is 345-kV.
The proposed transmission line is
736
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Page 5 of 11
The Project is approximately 37-40 miles of proposed double circuit 345-
2
kV transmission line expected to be supported by monopole steel structures.
3
typical in-line tangent structure is expected to be approximately 135-145 feet tall.
4
The line is expected to have structures spaced at 800 foot intervals depending on
5
terrain and crossing requirements.
6
7
Q13.
WHAT IS THE ESTIMATED SCHEDULE FOR THE PROJECT?
8
A.
The estimated schedule for the Project is set out in the following table:
Estimated Dates of:
Estimated Start
Date
Estimated
Com pletion Date
Right-of-way (ROW) and Land
March 2017
April 2018
Engineering and Design
Ma 2017
February 2018
Material and Equipment
Procurement
March 2018
Ongoing throughout
Construction
Construction of Facilities
2018-2019
2021
Energize Facilities
2021
Within 30 days of
Acquisition
completion of
9
hi_a__ T1_•_ • .1
i•^w• =il.o lo
lb VUl1Glll.^y
_
_
construction
aiiL,c,Pd.l.GU scneaule ana is subject to change.
10
11
IV.
CONDUCTOR AND STRUCTURE SELECTION
12
Q14.
WHAT CONDUCTOR IS PROPOSED FOR THE PROJECT?
13
A.
The conductor is anticipated to be twin-bundled (2) 1590 kcmil 54/19
14
"FALCON" ACSS.
737
A
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
Page 6 of 11
1
Q15.
WHY IS THIS CONDUCTOR TYPE PROPOSED?
2
A.
This
3
conductor type
meets the
Megavolt-amperes
( "MVA")/current and
temperature requirements proposed for the Project.
4
5
Q16.
WHAT IS THE CURRENT RATING FOR THIS CONDUCTOR?
6
A.
The current rating for the conductor is 2350 MVA or 4140 amps per phase.
Q17.
PLEASE DESCRIBE THE TRANSMISSION STRUCTURE THAT IS
7
8
9
10
EXPECTED TO BE USED ON THIS PROJECT.
A.
The final transmission structures will be designed by the selected EPC contractor.
11
However, as noted above, and based on the known project parameters, structures
12
are expected to be approximately 135-145 feet in height on average and maintain
13
a typical 800 foot span length. Structures are expected to be single monopoles
14
supporting two circuits or six total phases and two overhead shield wires all on
15
arms.
16
constructed on two single poles supporting a single circuit and shield wire
17
respectively. Under some circumstances, such as river crossings, lattice structures
18
may also be used. Examples of the conceptualized structures can be seen in the
19
sketches included with the Environmental Assessment and Alternative Route
20
Analysis Report as Figures 2-1 through 2-4.
There is some potential that large angle deadend structures would be
738
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Q18.
2
3
Page 7 of 11
WHAT FACTORS LED TO THE APPLICANT'S DECISION TO USE A
SINGLE-POLE STRUCTURE?
A.
Single pole structures offer a limited footprint and significantly reduced
4
construction requirements as related to similar lattice tower options. Additionally,
5
during the public meetings held for this Project, landowners indicated a
6
preference for the single-pole steel design.
7
V.
8
9
PROJECT IMPACT ON RIGHT-OF-WAY , FACILITIES ,
AND OTHER UTILITIES
10
Q19.
PLEASE DESCRIBE THE RIGHT-OF-WAY IMPACTED BY THIS PROJECT.
11
A.
The Project is expected to have approximately 37 to 40 miles of right-of-way and
12
approximately 74 to 80 miles of circuit. The right-of-way will be 150 feet wide,
13
but may be wider in exceptional circumstances.
14
requirements were determined assuming the minimum electrical clearances
15
requirements of the NESC to ground and potential obstructions, such as, but not
16
limited to, vegetation, buildings, or sign posts located at the edge of the right-of-
17
way. Width evaluations were made assuming the typical 800 foot span length and
18
average 135-145 foot structure heights under mandated wind conditions providing
19
for conductor blow out to the edge of the right-of-way.
Technical right-of-way width
739
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Q20.
Page 8 of i l
PLEASE DESCRIBE WHETHER ANY NEW OR EXISTING HVDC
2
CONVERTER STATIONS, SUBSTATIONS OR SWITCHING STATIONS
3
WILL BE ASSOCIATED WITH THE PROJECT.
4
A.
Rusk and Panola switching stations are associated with the Project.
Panola
5
Station will connect with the SCT high-voltage direct current
("HVDC")
6
converter station located across the border in Louisiana.
7
8
Q21.
9
10
WHAT EFFECT WILL THE PROJECT HAVE ON OTHER ELECTRIC
UTILITIES?
A.
The Rusk Switching Station will be owned and operated by Oncor Electric
11
Delivery Company and will serve as the origination point for the Rusk to Panola
12
double-circuit 345-kV transmission line. Mr. Parquet's direct testimony discusses
13
reliability and interconnection studies performed by Oncor that evaluate the effect
14
of the Project on the ERCOT grid. Other utilities in the vicinity of the project
15
include Deep East Texas Electric Cooperative, Inc., Panola Harrison Electric
16
Cooperative, Inc., Rusk County Electric Cooperative, Inc., and Southwestern
17
Electric Power Company. The Project is expected to have little or no physical
18
effect on these existing electric utilities.
740
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
Page 9 of 11
I
VI.
ESTIMATED COST AND ENGINEERING OF THE PROPOSED ROUTES
2
Q22.
WHAT IS THE ESTIMATED COST RANGE FOR THE PROJECT AND THE
3
4
PANOLA SWITCHING STATION?
A.
5
The estimated costs for the routes proposed in the application and for the Panola
Switching Station are shown in Exhibit CM-1.
6
7
Q23.
DO THE ESTIMATED COSTS PROVIDED IN THE APPLICATION
8
REFLECT THE ACTUAL TRANSMISSION PROJECT COSTS FOR THE
9
ROUTE TO BE CONSTRUCTED?
10
A.
No. The costs are only estimates. Since the approved line route has not yet been
I1
determined by the Commission or surveyed by the construction team, the final
12
cost estimates for the proposed line segments have not been performed.
13
estimates provided in Exhibit CM-1 are based on factors such as estimated
14
structure costs and estimated costs per mile for right-of-way, conductor, and
15
labor.
The
16
17
Q24.
18
19
DOES
THE PROJECT ADEQUATELY CONSIDER ELECTRICAL
EFFICIENCY AND RELIABILITY?
A.
Yes, the proposed transmission project adequately considers electrical efficiency
20
and reliability. A transmission line constructed on any of the alternative routes
21
will be engineered so that the line itself will be electrically efficient and reliable.
741
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
1
Q25.
Page 10 of 1 1
DOES THE TRANSMISSION LINE DESIGN FOR THE PROJECT MEET THE
2
REQUIREMENTS OF THE NATIONAL ELECTRICAL SAFETY CODE
3
(NESC)?
4
A.
Yes, the transmission line design will meet the requirements of the latest NESC
5
and any local or Electric Reliability Council of Texas ("ERCOT") design
6
requirements. In addition to being required by law, these requirements will also
7
be specified by Garland and Rusk to the EPC contractor.
8
9
VII.
ALTERNATIVES CONSIDERED
10
Q26.
WERE OTHER ALTERNATIVES TO THE PROJECT CONSIDERED?
11
A.
The Project is designed to connect the SCT transmission project to the ERCOT
12
grid at the locations specified in FERC Docket No. TX 11-1-001, so alternatives
13
such as upgrades to existing facilities, distribution upgrades or distributed
14
generation are not available.
15
16
VI1I. SUMMARY AND CONCLUSION
17
Q27.
PLEASE SUMMARIZE YOUR TESTIMONY.
18
A.
In this application, Garland proposes a double-circuit 345-kV transmission line
19
from the new Rusk Switching Station to the new Panola Switching Station. My
20
testimony summarizes estimated schedule and cost for the Project, conductor and
21
structure selection, and potential impacts on right-of-way, facilities, and other
22
utilities.
742
Docket No. 45624
City of Garland
Direct Testimony of Chris McCall
Q28.
DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
A.
Yes, it does.
Page 11 of I I
743
Exhibit CM-1
PUC Docket No. 45624
Page 1 of 2
°'-
^
N
C^0
N
Cl
^
^
^ w M N N
OR
ro
N
^D
ep
^
M
N
O
^
^
t0
a n
^
-
00
-
p
N
N
N
^p
p
N
W
N
p
fD
N
^
h
w
N N
N
"
N
a0
nj
0
16
1f^
^.
^
V
N
NO
N
-
N
M
Pf
N
^p
M
tD
Of N
^
m
P
N
N
V
Qi
^
Ill
06
Ol
OS' N
M
•
^
•
-
'4
Oct
'n
-
O
O
^
N
N
O
CP
W V
a
b
O
N
C
n
N
V)
N
m
'
ip
N
V
^
O
N
$
N
N
N
O
Y1 0
N' N
m a0
tp N
n
a
^
^
GN
N
m
a0
N
0 N
ay
O y
O
NW ^
3
p
m
m
A
O
Oc
N
N
N
a
O^ O
O O
^
p
CO
-
-
Q
O
In
N
O C
D O
U
N
H `o
n
n
9
4`7
O
N
N
N
e
O
N J O
^ U pD
C
O
a
N
N
o
M
0
C's
w
N
Q
O
N N
C
O
^ O.
U
C y ^ 05
C C^ J O O
d ?
^i ^ E c m
° °
W
O
cc '`ct ^d
?
0a
w 3
U
C
O
m
M
m m
U
N
N
N
C
d T
R QO 'q
C9
C
C
rn
E
a
N
°i
W
N
O
-
C
LL 11
C
-
-O
W
O
`
O
C
o
a ac y
E
a°i
2
C
J
40i - A
d
L
C
_
m
m o
G n C
O O T O
NN
z R
E lpW N
2-6
uCT-3
C O F ^ J
0
E
E r
9 y
m a c
N
N
N
>
0
C
J
f0
N
C
d
m rMO
^ ^ p w E
yl ,^ N tp J
O
C
o
2
U
U
w
t0
N f
y
d
° N
E
`°
a
m
a:?
0 a cJi c c
0z
_
U
U .2
wD
UO
N
C O O J
N
d U
^ C e > L
^QI
°.Z
U^ C N ry ^l
O C O ^
U U
Q U Q H Q
- N Cl V N (D
1
744
Exhibit CM-1
PUC Docket No. 45624
Page 2 of 2
co
0
Cl
to
T
N
0
°
0
0
o
0
0
o
0
^
O)
LO
O
CO
^
LO
N
Lr
^
0
C
0
N
^
a>
p
0
N
N
Ili
N
^
_^
-.C
r••.
U
N
U
C
(C
O
U
V
0
ai
R
0
Q
cz
C
a)
N
C
0
y
,
O
•^^
U
C
N
O
C
^
C
0
U
^
^
i
O
d
m
N
.'^
^
Cu
N
613^
6131
60^ 60^ 611-^
_O
^
N
O
N
O
64 ^ '69
U
C
^
CU
0
U)
U
U
a)
(D
0
N
CO
Cy.
p
^
V
^
a)
Cu
U
(D
O
-0
E
N
0
U
C
0
^
,.^.
U)
tm
r'
R ^
^ N
^ lQ
0 0
^
C
on.
tn
Q
^
CU
_
:D
•-
C
Cu
U
RS
_
U
C:
•^
_^
^_
(n
(n
4)
^=
•`-'
C
CO
0
O
C
U
U
O
C
0
U
^
i
i
(0
C/)
W ^
Q
0C
Cz
"d
C
D
^
(CS
0)
O
a)
a)
^
c
0) C
oc
c
U
C
N
E
0
:3
0
U
`^
^
0
u
C
C
C 0
a U cU 0 ' t0 C
w
0
^
Cu
(L
a)
fV
m
E
U
C
tSf
O
C
Cn
a)
(n
^
U
C
C :3
U
3:
0
O
C
a) (D CU
al
E
O a) ^
N -a ~•O
^ 0 U
^
U
N
Cu _0 N
U 0 O
N (z
0 c
^
0
O C6
N Rf
^ N
0
^
70 C
CD
U
U
cfl
a)
(t$
C:
_
o^
O
C
0
a)
a)
Q
J
U
^
Ca
0
•
0C)
CY)
^
H
a)
^
R
U
CO 0
U U
U ^
^ O
O U
0,0
C LO
a)
cV
E
(0
w
m
^
0 UQ
a CU
Cz ^i
T- N CY) 11,
0
Z
U U
745